We know that you care about your personal data and how it is used. We want you to trust that IEVA brand uses your personal data carefully This Privacy Notice will help you understand what personal data we collect, why we collect it and what we do with it.
As you read our Notice, please keep in mind that it applies to IEVA, as defined below.
Please take a moment to familiarise yourself with our privacy practices and let us know if you have any questions by sending us an email firstname.lastname@example.org.
We have tried to keep this Notice as simple as possible, but if you’re not familiar with terms, such as cookies, IP addresses, and browsers, then please read about these key terms first.
You have the right to object to certain uses of your personal data including the use of your personal data for direct marketing. See what are your rights and how you can exercise them here.
1. WHO IS COLLECTING IT ?
Any personal data provided to or collected by IEVA SAS, 66 Av. des Champs-Élysées, 75008 Paris, FRANCE (the data controller).
This Privacy Notice applies to personal data collected by IEVA SAS in connection with the services and products we offer.
This Privacy Notice also applies to IEVA’s marketing content, including offers and advertisements for IEVA products and services, which we (or a service provider acting on our behalf) send to you on third-party websites, platforms and applications based on your site usage information. These third-party websites generally have their own Privacy Notice and Terms and Conditions. We encourage you to read them before using those websites.
2. WHAT PERSONAL DATA IS BEING COLLECTED?
Personal data means any information that can be used to identify directly or indirectly a specific individual. This definition includes personal data collected offline through our Consumer Engagement Centres, direct marketing campaigns, sweepstakes and competitions and online through our websites, applications and branded pages on third-party platforms and applications accessed or used through third-party platforms.
We may collect personal data from a variety of sources, this includes :
- Personal data you give us directly,
- Personal data we collect automatically, and
- Personal data we collect from other sources.
You may be asked to provide your personal data when you are in contact with us. The joint data controllers may share this personal data with each other and use it in a manner consistent with this Privacy Notice. We may also combine it with other information to improve our products, services, content, and advertising.
You are not required to provide IEVA the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have. We use the information collected to improve the services and features of IEVA applications.
WHAT PERSONAL DATA IS COLLECTED IN ADDITION BY THE IEVA APPLICATION?
When you allow us to collect specific location information about your location on IEVA applications, we use this information to provide and improve certain features of our services. We also use your information to make deductions and show you more relevant content. Here are some examples: information such as your height, weight, gender and age allows us to improve the accuracy of the daily statistics we present to you related to your use of the IEVA application.
We may collect and use different types of information about your location, depending on the features you use, to provide you with a more relevant experience on the IEVA application.
Some of the application’s features require accurate location information. Your device collects data to estimate or measure various parameters such as pollution, humidity, temperature, light, ambient noise or the number of steps you take. When your device synchronizes with our application, the data stored on your device is transferred from your device to our servers.
For optimal use of the IEVA application, you should enable the application’s location services, which use information such as GPS signals, device sensors, Wi-Fi access points and relay antenna identifiers to determine or estimate a specific position. You can decide to disable the device’s location services at any time. We collect this type of data if you allow us access to your location. You can always remove this access from us using the settings of your IEVA application.
Based on your sleep data, we can make inferences about your sleep patterns and provide you with personalized advice to help you improve your sleep. We use your information when necessary to send you notifications about the Services and to respond to you when you contact us. We also use your information to inform you of new features or products that we think may be of interest to you. You can control marketing communications and most notifications related to our Services using the IEVA application settings.
2. Ways we use to collect your personal data
- Personal data you give us directly. We collect data about how you use our services and products, such as the types of content you view or engage with, or the frequency and duration of your activities. We also collect personal data you provide us when you sign up for a marketing newsletter, complete a survey or register for an account to buy our products. In so doing, we may ask for personal data, such as your name, gender, date of birth, address, email address, telephone number or credit card details. Some IEVA brands may collect “ special categories of personal data” about you with your explicit consent. For more information on the special categories of data we collect and how we use it, please refer to the relevant section below.
- Personal data we collect from other sources. We collect personal data from other sources including our trusted partnerships with third-parties and where we operate IEVA accounts on third-party platforms: For example, when you use the “like” functionality on Facebook or the +1 functionality on Google+. Additionally, we receive information about you and other visitors’ interactions with our advertising to measure whether our advertising is relevant and successful. We also collect information about you and your activities from a third-party when we jointly offer services or products, or from third-party data enrichment providers (to find out more see our privacy key terms here) who may deliver insights to IEVA about the personal data we hold.
2.3 How do we protect children’s privacy?
We understand the importance of taking extra precautions to protect the privacy and safety of children using IEVA products and services.
IEVA’s Site and Application website is designed and intended for use by adults only.
For example, you authorization is required for us to collect your age in order to use the Application. We sometimes use your personal datas to check your âge and eventually and enforce any age limit.
3. WHAT PURPOSE DO WE USE YOUR DATA FOR?
We collect, process and disclose your personal data only for specific and limited purposes. For example, to process your payments, to assess and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our websites and mobile applications, to provide personalized products, communications and targeted advertising as well as product recommendations to you.
We also create profiles by analyzing the information about your online surfing, searching and buying behavior and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments.
Additionally, IEVA processes your personal data also using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data.
We collect, process and disclose your personal data for the following purposes:
- To process your payments, if you purchase our products, to provide you with your order status, deal with your enquiries and requests, and assess and handle any complaints;
- To process and answer your inquiries or to contact you to answer your questions and/or requests;
- To develop and improve our products, services, communication methods and the functionality of our websites;
- For the purposes of competitions or promotions that you have entered;
- To communicate information to you and to manage your registration and/or subscription to our newsletter or other communications;
- To manage our everyday business needs regarding your participation in our contests, sweepstakes or promotional activities or request;
- To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise;
- For internal training and quality assurance purposes;
- To understand and assess the interests, wants, and changing needs of consumers, to improve our website, our current products and services, and/or developing new products and services; and
- To provide personalized products, communications and targeted advertising as well as product recommendations to you.
When we collect and use your personal data for purposes mentioned above or for other purposes, we will inform you before or at the time of collection.
Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.
In some cases, we rely on legitimate interest for processing your personal data. A legitimate interest could exist for example, when you sign up for a loyalty scheme with one of our brands and we use the personal data collected to conduct data analytics to improve our products or services. This ground will only be used where it is necessary to achieve a legitimate interest, for example to assist in the performance of a contract, or to optimise a service, and does not outweigh your rights as an individual. This legal basis will only be relied upon where there is no less intrusive way to process your personal data. We can assure you that if legitimate interest is used as a ground for processing your personal data, we will keep a record of this and you have the right to ask for this information.
IEVA uses your personal data to build profiles. We create profiles by analyzing the information about your online surfing, searching and buying behavior and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments.
These segments are used by IEVA to personalize the website and our communications to you (such as showing relevant content to you when you visit our site or in a newsletter to you), and to display relevant offers and advertisements from the IEVA brand on the IEVA site, and via third-party websites. The segments can also be used for third-party campaigns on the IEVA site. IEVA profiles your data where you have provided consent for us to do so; for example, accepting the setting of cookies on your browser online or signing up for email newsletters from one of our brands.
You can withdraw your consent to prevent your personal data being used this way at any time using the manage cookies section of our Cookie Notice or un-subscribing to the use of your email address if you have logged into one of our websites or signed up to any marketing newsletters.
By way of example:
IEVA collects data, with your consent, from:
- Our websites about what you view and the way you interact with our content;
- Our digital display advertising that we serve to you on social platforms and other publisher’s websites; and
- Forms you fill in online and send to us about what your interests are,
- Forms you fill in on our Skin diagnostic tools following,
We also track the products you buy when you click on one of our display adverts and go on to purchase something from a selection of our retail partners.
If you have asked to receive emails, SMS or push notification communications from us, we track whether you open, read or click on the content to see what you are interested in so that we can give you more content that we think you are more likely to enjoy.
We use this data to profile your likes and dislikes. For instance, if we see that you are regularly viewing specific IEVA products on our www.ieva.io website, and you have opted in to receiving emails from us, we might give you an update on the new complementary IEVA products and skin care routines that have just hit the site for your interest, or we may tailor our web content when you visit towards things we think you’ll be most interested in.
Based on this profile information, we may also give you advertising that we think you will like and want to see as you view content from us or from our network of publishers that we advertise with. Sometimes, with your consent, we may use your current location to serve advertising to you that is to do with promotions or events that are happening nearby that we think you might be interested in.
We may also use information you have provided to selected third-parties and consented to be shared, like your age, gender, life stage, lifestyle and wider interests to identify people who we think will have similar interests to you and who we believe will be interested in similar advertising.
3.2 Automated decision-making
In some instances, IEVA processes your personal data using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data.
IEVA uses automated emailing scenarios generating automated email campaigns based on your browsing behavior, purchase habits, birthday.
We will not make decisions based solely on automated decision making that have significant impact on you. If we do so we notify you and provide you with clear information about our decision to rely on automated processing to make our decision and our lawful basis for doing so. For example IEVA, processes your personal data using automated means only if it is necessary for the entering into or the performance of a contract with you, or when you have given your explicit consent.
Vous avez le droit de ne pas faire l’objet d’une décision fondée exclusivement sur un traitement automatisé si la décision produit des effets juridiques vous concernant ou vous affectant de manière significative. En particulier, vous avez le droit :
- To obtain human intervention;
- To express your point of view;
- You have the right not to be subject to a decision which is based solely on automated processing and which produces legal or other significant effects on you. In particular, you have the right: to obtain human intervention; to express your point of view; to obtain an explanation of the decision reached after an assessment; and
- to challenge such a decision.
4.WHO WILL IT BE SHARED WITH?
As a global business, IEVA shares your personal data internally and with selected third-parties. For example, we share your personal data with third-party service providers, other third-parties, as well as in case of business transfers or legal disclosure.
As a global business, IEVA shares your personal data internally and with selected third-parties in the following circumstances:
- Third-party service providers. In order to carry out your requests, respond to your inquiries, fulfill your orders, honor coupons, provide you with samples, enable you to participate in sweepstakes or make various other features, services and materials available to you through our websites we share your personal data with third-party service providers that perform functions on our behalf. There are companies that: host or operate IEVA’s websites, process payments, analyse data, provide customer service, postal or delivery services, and sponsors or other third-parties that participate in or administer our promotions. They have access to personal data needed to perform their functions but may not use it for other purposes. Further, they must process this personal data in accordance with this Privacy Notice and as permitted by applicable data protection laws and regulations.
- Other third-parties. Your personal data will also be used by us or shared with our sponsors, advertisers, advertising networks, advertising servers, social media networks, and analytics companies or other third-parties in connection with marketing, promotional, data enrichment (to find out more about our privacy key terms follow the link) and other offers, as well as product information.
- Business transfers. Your personal data will be used by us or shared with the joint data controllers for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets, subsidiaries or business units. In such transactions, your personal data generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, you consent otherwise). If another entity acquires us, our businesses or substantially all or part of our assets, or assets related to IEVA’s website, your personal data will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such personal data will be considered an asset of ours and as such it is possible they will be sold or transferred to third-parties.
- Legal disclosure. We may transfer and disclose your personal data to third-parties:
- To comply with a legal obligation;
- When we believe in good faith that an applicable law requires it;
- At the request of governmental authorities conducting an investigation;
- To detect and protect against fraud, or any technical or security vulnerabilities;
- To respond to an emergency; or otherwise
- To protect the rights, property, safety, or security of third-parties, visitors to IEVA’s website, IEVA’s diagnostic tools, INTUISKIN’s smartphone application, INTUISKIN or the public.
4.1. International data transfers
IEVA shares personal data internally or with third-parties for purposes described in this Privacy Notice. IEVA will only send personal data collected within the European Economic Area (EEA) to foreign countries in circumstances such as:
- To follow your instructions;
- To comply with a legal duty; or
- To work with our agents and advisers who we use to help run our business and services.
- If we do transfer personal data to outside of the EEA, INTUISKIN will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of the following safeguards:
- Transfer to a non-EEA Country whose privacy legislation ensures an adequate level of protection of personal data to the EEA one;
- Put in place a contract with the foreign third-party that means they must protect personal data to the same standards as the EEA; or
- Transfer personal data to organisations that are part of specific agreements on cross-border data transfers with the European Union (e.g., Privacy Shield, a framework that sets privacy standards for data sent between the United States and the European countries).
5.HOW DO WE PROTECT YOUR PERSONAL DATA?
IEVA takes the security of your personal data very seriously.
We take every effort to protect your personal data from misuse, interference, loss, unauthorised access, modification or disclosure. Our measures include implementing appropriate access controls, investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymize and anonymize personal data wherever possible.
Access to your personal data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third-parties.
6.HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
Nous conserverons vos données personnelles le temps nécessaire à l’accomplissement de l’objectif qui était poursuivi lors de leur collecte. Par exemple, lorsque vous nous achetez un produit en ligne, nous conservons les données liées à votre achat, nous permettant ainsi d’exécuter le contrat spécifique que vous avez accepté et après quoi, nous conservons les données personnelles pendant une période nous permettant de traiter ou de répondre à des réclamations, des demandes d’informations ou des inquiétudes concernant l’achat.
Your data may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you.
We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it.
We will actively review the personal data we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business or consumer need for it to be retained.
7. WHAT ARE YOUR RIGHTS?
Your rights concern the way in which your personal data are processed. You can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email to email@example.com
- The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. Therefore, we’re providing you with the information in this Notice.
- The right to access and rectification. You have the right to access, correct or update your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact us.
- The right to data portability. The personal data you have provided us with is portable. This means it can be moved, copied or transmitted electronically under certain circumstances.
- The right to be forgotten. Under certain circumstances, you have right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.
- The right to restrict processing. Under certain circumstances, you have the right to restrict the processing of your personal data.
- The right to object. Under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (i.e., receiving emails from us notifying you or being contacted with varying potential opportunities).
- The right to lodge a complaint with a Supervisory Authority. You have the right to lodge a complaint directly with any local Supervisory Authority about how we process your personal data.
- The right to withdraw consent. If you have given your consent to anything we do with your personal data (i.e., we rely on consent as a legal basis for processing your personal data), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your personal data at any time by contacting us with the details provided below.
- Rights related to automated decision-making. You have the right not to be subject to a decision which is based solely on automated processing and which produces legal or other significant effects on you. In particular, you have the right:
- To obtain human intervention;
- To express your point of view;
- To obtain an explanation of the decision reached after an assessment; and
- To challenge such a decision.
Further information and advice about your rights can be obtained from the data protection Regulator in your Country.
8. HOW DO YOU CONTACT IEVA?
If you have any questions or concerns about IEVA’s Privacy Notice or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please do so by sending an email to firstname.lastname@example.org.
When a privacy question or access request is received we have a dedicated team which triages the contacts and seeks to address the specific concern or query which you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. If you are unsatisfied with the reply received, you may refer your complaint to the relevant Supervisory Authority in your Country. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
9. HOW DO WE KEEP THIS NOTICE UP TO DATE?
We will update this Privacy Notice when necessary to reflect customer feedback and changes in our products and services. When we post changes to this statement, we will revise the “ last updated” date at the top of this Notice. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes). We will keep prior versions of this Privacy Notice in an archive for your review.
We will not reduce your rights under this Privacy Notice without your consent.
10. ADDITIONAL PRIVACY TERMS OR NOTICES
In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or notices. We encourage you to read these additional terms or notices before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or notices will be made prominently available to you.
11. KEY TERMS DEFINITIONS
- IP address: An IP address, or simply an “IP,” is a unique address that identifies a device on the Internet or
- a local network. It allows a system to be recognized by other systems connected via the Internet protocol.
- Cookie: A cookie is a small amount of data generated by a website and saved by your web browser.
- SMS: Stands for “Short Message Service.” SMS is used to send text messages to mobile phones.
- Push notification: A push notification is a message that pops up on a mobile device. Push notifications look like SMS text messages and mobile alerts, but they only reach users who have installed your app.